Global HR Risk Management Assessment
Global HR Risk Management Assessment
MANAGEMENT
ASSESSMENT REPORT
TABLE OF CONTENTS
This review was designed to obtain and evaluate the existing global HR risk management
technique capabilities (using the capability maturity model). We then worked with management to
Approach identify opportunities to enhance these capabilities and project a “future state” of risk
management capabilities based on management action plans. Internal audit will monitor the
implementation of scheduled management action plans related to this review.
3
INTERNAL AUDIT RESULTS: GLOBAL HR RISK
MANAGEMENT ASSESSMENT
Objective and Scope
This objective was to evaluate global HR risk management techniques. We utilized the capability maturity model (CMM) to
identify the “current-state” and “future-state” models, reflecting planned management actions.
Results
• The assessment determined that the most mature HR risk management practices exist in the U.S. This is primarily due to the
utilization of the (Insert System) in the U.S., which is the technology used to support many critical HR processes (e.g., HR
admin, new-hires/terminations, comp and benefits, etc.). There are initiatives underway to extend the reach of corporate-level
risk management. The assessment summarized:
− Recruiting and hiring: Many of these activities are unique to each region/country, primarily due to legal or cultural
variations. The assessment noted that while there are some formal processes (forms, policies, etc.) in place in the U.S.,
they are generally not implemented on a global basis. There are initiatives underway to standardize/improve personnel
selection processes using competency models and interviewing strategies.
− Performance management/organizational development: There are activities underway to develop a more effective
process for measuring employee performance and linking it to corporate objectives.
− Timekeeping and compensation: Management is implementing enhanced PTO monitoring. U.S. salary admin
processes are based on metrics and market surveys, while those in other regions generally are not. There is an initiative
to utilize market data as it becomes available.
− Policies and procedures: The company has incorporated key policies and procedures into the (Insert Policy). The
standards were deployed globally, effective (Date). Compliance with these on a global basis is not yet subject to
management monitoring.
− Legal requirements: There is a need to formally assign responsibility for human resources compliance risk more often on
a global basis. There is an initiative to formalize the responsibilities of the global HR compliance director.
• Management detailed 16 action plans designed to enhance risk management capabilities. These plans are listed beginning
on Page 17.
4
RISK MANAGEMENT MODEL DEFINED
The risk management model was used to obtain management's assessment of HR risk management capabilities. This model
considers the elements of risk management and the maturity of risk management capabilities for each element. The objective for
any company is to tailor risk management activities to a maturity that balances the cost of those activities with management’s
tolerance of risk.
Elements of Risk Management:
Performance
Recruiting & Management & Timekeeping & Policies & Legal
Hiring Organizational Compensation Procedures Requirements
Development
• Impacts the • Manages • Timekeeping controls • Articulates risk • Managing compliance
company’s image accountability and reduce the risk of management strategies. with legal
and the quality of responsibility among unnecessary payroll • Guides management requirements reduces
personnel that will employees. costs. and risk owners toward exposure to negative
apply risk • Primary means of • Compensation is the achieving risk goals. publicity and
management executing risk primary incentive to increased litigation.
activities. management ensure the quality of risk
strategies and policies. management practices.
Risk Management Capabilities:
Global human resources is a clear source of competitive advantage. World-class human resources is sustained through maximizing the value
Optimized
of well-defined processes and strategies and addressing issues proactively. Operational, financial and key HR strategies are in alignment.
HR risks and opportunities are formally and effectively addressed in strategies and policies. Processes are well-defined, communicated,
Managed monitored, measured and aligned to operational, financial and HR strategies. HR leaders and tools are positioned to execute the strategies
Process Maturity
and processes.
Some HR strategies and plans address global risks and opportunities. Policies and standards are documented and accountability for HR
Defined
strategies is clearly defined. Empowered leaders and professionals are driving action. Standard reporting is used to monitor performance.
The need to manage HR risks and opportunities is becoming more evident. Processes are being established, but some standards are not
Repeatable documented. Many standards are repeated and informal. There is high reliance on key individuals to ensure that objectives are met. The need
for good data and information is becoming evident. Some formal reporting exists to monitor performance.
HR processes are reliant largely on the individual heroics of local HR leaders. Global consistency is generally not monitored, and reporting is
Initial ad hoc. There are no effective processes, strategies, standards and policies in place. HR risks are managed and controlled in an ad hoc
fashion.
5
HR RISK MANAGEMENT MODEL: CURRENT-STATE
ASSESSMENT (1/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Optimized Company recruiting Company performance Company compensation There is continuous Company compliance
strategies are frequently management and strategies are frequently company processes and management strategies
updated to ensure development strategies are updated to ensure controls improvement. The are frequently updated to
continual alignment. The frequently updated to ensure continual alignment. The company facilitates ensure continual
company facilitates continual alignment. The company facilitates continuous benchmarking alignment. The company
continuous improvement. company facilitates continuous and best practice usage. facilitates continuous
There are fully continuous improvement. improvement. There are There is extensive improvement and
developed and There is extensive cross- fully developed and individual cross-training. experienced personnel
integrated metrics. Fully training for individuals. There integrated metrics, fully continuously train others.
automated reporting are fully developed and automated reporting and There are fully developed
exists and there is integrated metrics, fully consistent follow up and and integrated metrics,
consistent follow up and automated reporting, and action planning. fully automated reporting
action planning. consistent follow up and Sophisticated models and consistent follow up
Sophisticated models are action planning. Sophisticated are fully integrated in all and action planning.
Process Maturity
fully integrated into all models are fully integrated key decisions. Sophisticated models are
key decisions. Results into all key decisions. fully integrated into all key
are well-documented. decisions.
Managed There is a formal A formal strategy exists and is A formal strategy exists Company policies and A formal strategy exists
strategy aligned with aligned with company and is aligned with procedures are updated and is aligned with
company overall strategies. A formal training company strategies. regularly. HR objectives company overall legal
corporate strategy. A program exists. Experienced Authority and are defined at the front- compliance strategies. A
formal training program personnel perform with few accountability are clearly line level to immediately formal training program
exists. Accountability and errors. Authority and defined and understood. identify interdependencies exists, and experienced
authority are clearly accountability are clearly There is generally and people issues. personnel are involved in
defined and well- defined and understood. automated reporting and all legal compliance
understood. There are There is generally automated concerted follow up, aspects. Authority and
well-developed metrics reporting and concerted follow typically resulting in accountability are clearly
and general automated up, typically resulting in actions. Sophisticated defined and understood.
reporting is utilized. actions. Sophisticated models models are available for There is generally
Sophisticated models are are available for decision decision making. automated reporting and
available for decision making. concerted follow up,
making. typically resulting in
actions. Sophisticated
models are available for
decision making.
6
HR RISK MANAGEMENT MODEL: CURRENT-STATE
ASSESSMENT (2/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Defined Recruiting goals are Company job requirements Company timekeeping The company has a The company has
documented, but with are well-defined and and compensation standard strategic assigned and
limited alignment with understood. Training supports responsibilities and planning process with communicated
company strategies and job needs. There are requirements are well- clear role definitions and responsibility for legal
defined policies. Job generally experienced defined and understood. budgets. There is manual compliance. These
requirements are well- personnel within the Reports are reviewed, process performance, requirements are well-
defined and understood. organization. Many metrics but follow up is costs and policy defined and understood,
Training supports job are developed. Reports are inconsistent. There are compliance monitoring. and training supports job
needs. There are well- reviewed, but follow up is well-developed models needs. There are
developed models inconsistent. There are well- available for decision generally experienced
available for decision developed models available making. personnel within the
making. for decision making. organization. Many
metrics are developed.
Reports are reviewed, but
Process Maturity
follow up may be
inconsistent. There are
well-developed models
available for decision
making.
Repeatable Basic skill requirements Basic skill requirements are Timekeeping procedures The company has some Basic skill requirements
are defined by the defined by the company. are defined by the standard policies and are defined by the
company. There is some There is some training company. There are no procedures (e.g., company. There is some
training available. There available, and there are some formal metrics for management by objectives training in the legal
is some formal reporting, competent personnel in the compensation. There is and prescribed requirements available
but it is inconsistently organization. There are no some formal reporting, documentation in place and there are some
used. There are some formal metrics. There is some but it is inconsistently but used inconsistently). informed personnel in the
systems available, but formal reporting, but it is utilized. There are organization; however,
they tend to be user- inconsistently utilized. There simple models used there are no formal
developed. are simple models used inconsistently for metrics or processes to
inconsistently for decision decision making. monitor compliance. There
making. is some formal reporting,
but it is inconsistently
utilized.
7
HR RISK MANAGEMENT MODEL: CURRENT-STATE
ASSESSMENT (3/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Initial/ The company has no The company has no formal The company has no The company has no The company has no
Ad hoc formal recruiting strategies or objectives. formal strategies or formally documented formal strategies or
strategies or objectives. Development is typically objectives. There is no procedures. The HR objectives. Adherence to
Recruiting is typically performed by inexperienced formal reporting, or strategy is a part-time legal requirements is
performed by and/or untrained people. reporting occurs as activity with no clear dependent on the local
inexperienced and/or There is no formal reporting, requested. There are no definition. individual’s knowledge.
untrained personnel. or reporting occurs as models to support Reporting occurs when
There are no models requested. There are no decision making, and no incidents occur and is
used to support decision models to support decision formal systems are limited.
making. Authority and making, and no formal utilized.
accountability are not systems are utilized.
defined. No formal
systems or databases
are used.
Process Maturity
8
CURRENT-STATE ASSESSMENT: SUPPORTING
DETAILS (1/4)
The following information supports management’s risk management elements classification. In each case where there is a
limitation in risk management capabilities, management has developed a specific strategy for improvement and provided
explanation as to why a strategy is not necessary to address the risk. These strategies are detailed starting on Page 17.
Recruiting & • Checklists are used in the U.S. to provide consistency in • Orientation is not standardized on a global scale to
Hiring new-hire activities. ensure consistency and efficiencies. (Strategy 1)
• Nationally, hiring needs are known via (Form) and job • The new-hire checklists themselves do not contain
descriptions, which also ensure that positions are filled with all relevant information and could be improved for
individuals who possess the requisite knowledge and skills. completeness. (Strategy 2)
• Questionnaires are used to provide the information needed • Not all new-hire tasks are audited for accuracy.
to generate job descriptions for new positions. Templates (Strategy 3)
are used to create job descriptions and salary grades. • The job description templates are not utilized
• The company posts its status in the U.S. as an equal globally. (Strategy 4)
opportunity employer. • Best targeting practices, selection criteria and post-
• Background checks are performed for all corporate hire assessments for various locations worldwide are
employees. They are done globally within the local law and not known, shared and utilized. (Strategy 5)
in accordance with client requirements. • Employment applications (and accompanying notes)
are not stored in a database. Assessing applicants is
redundant and inefficient for repeat applicants.
(Note: Management has evaluated a global
applications system and determined that the
benefit does not currently justify the cost.)
• Hiring personnel, including local managers, globally
are not required to attend training on hiring
techniques. (Strategy 5)
9
CURRENT-STATE ASSESSMENT: SUPPORTING
DETAILS (2/4)
Element Risk Management Activities Risk Management Limitations
Performance • There is a university, which includes online training courses, • Corporate management does not monitor high-risk,
Management & instructor-based courses and some third-party courses. non-domestic location processes. (Strategy 14)
Organizational • A learning management system is used (via the university • A task force for LEAP had to be created because the
Development online) to keep course records taken internationally, which program was not fulfilling the target objectives.
serve as transcripts. (Strategy 8)
• Employees who support the customer receive product • Voluntary turnover is partially attributed to poor
training, usually provided by the customer, before they ever communication and poor awareness of job
begin working. expectations and performance. (Strategy 9)
• A training center exists to provide worldwide information
sharing on training needs and efforts.
• A training program exists to ensure that new training courses
and materials are consistently and effectively designed
worldwide. Instructors are certified worldwide.
• A task force has been created to identify the leadership
evaluation assessment process’s (LEAP) strengths and
weaknesses for the agent’s promotion and team leads.
• A performance empowerment process (PEP) exists to
facilitate regular meetings between agents and team leads to
manage agent performance against account metrics.
• The management excellence program (MEP) has released a
series of workbooks for team leads and account managers.
The series is intended to be a standard all-inclusive learning
experience for operational management.
10
CURRENT-STATE ASSESSMENT: SUPPORTING
DETAILS (3/4)
Element Risk Management Activities Risk Management Limitations
Timekeeping & • The company participates in compensation surveys and • International salary grades are not periodically
Compensation reviews the compensation trends results in the U.S. market. reviewed for market comparison. There is some
• Salary grades in the U.S. are periodically reviewed for market international salary expense macro analysis. Market
comparison. data is being used as it becomes available (e.g.,
• Payroll changes, such as position change, pay change and recently, data for the [Country] was made available).
leave of absence, require an employee change form. (Strategy 5)
• Most hourly employees track their time automatically via • Payroll changes are not audited for accuracy.
SIMS. Managers review and approve payroll reports for (Strategy 10)
accuracy. • SOA ’04 reported ineffective manager review and
• Salaried employees submit exception reports to account for hourly employee’s time approval that was not reported
personal time off. Emails are distributed regularly to remind via SIMS. (Strategy 11)
employees to properly report this information on their • SIMS does not generate exception reports for
timesheets. monitoring purposes. (Strategy 11)
• Data integrity audits are periodically performed on payroll • The managing personal time off (PTO) process is
calculations/allocations by the compensation department. ineffective and may be costly because salaried
• Bonuses are based on business performance and KPIs that employees only submit time sheets when they take
are established by the manager and employee together. PTO. If they fail to report PTO, the company may be
paying for unearned PTO. (Strategy 11)
• Actual performance of KPIs are reported by the supervisor at
the end of the period and audited by the compensation
department upon submission.
• KPIs are developed from scorecards, which communicate
corporate objectives and/or goals. The goal of this process is
to compensate employees in accordance with the company’s
established guidelines and/or strategy.
• Pay increases are determined by the merit process and
budget.
• An HR and board compensation committee exists and meets
at least once each quarter.
11
CURRENT-STATE ASSESSMENT: SUPPORTING
DETAILS (4/4)
Element Risk Management Activities Risk Management Limitations
Policies & • HR policies and procedures are reviewed annually and • HR policies and procedures were incorporated into
Procedures updated by the corporate HR director for accuracy, unless a the global standards of conduct for compliance and
new law or regulation requires an immediate update. integrity in (Date). These have not yet been subject
• As part of standards of excellence (SSE), a global to management review for effectiveness and
employee survey is distributed annually to help the application consistency. (Strategy 13)
company understand how employees view their culture,
growth, development potential and to determine employee
satisfaction.
• A regional HR director will oversee the final weeks of a site
closing to ensure the proper retention of documents.
Legal • Support for terminations in the U.S. must be reviewed by • Management has plans to include responsibility for
Requirements legal. Outside of the U.S., the local HR manager is global HR compliance into the director of
responsible for termination reviews. Legal counsel is employment compliance’s duties and responsibilities.
available at all locations as well. Until these are in place, there is limited management
• Merger and acquisition authority includes HR leadership in focus on legal compliance aspects of HR
pre-deal or due diligence activities. internationally. (Strategy 16)
• Executive contracts are reviewed for compliance with HR (Note: Internal audit’s [Year] regulatory compliance
and corporate strategies by (Title). risk management report details several management
action plans designed to enhance global compliance
activities, including those associated with human
resources considerations.)
12
FUTURE-STATE ASSESSMENT: BACKGROUND
Management has established a risk tolerance level for each risk management element. Implementation
of the strategies is intended to enhance overall risk management capabilities to an acceptable level of
risk based on management’s tolerance.
13
9
HR RISK MANAGEMENT MODEL: FUTURE-STATE
ASSESSMENT (1/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Optimized Company recruiting Company performance Company compensation There is continuous Company compliance
strategies are frequently management and strategies are frequently company processes and management strategies
updated to ensure development strategies are updated to ensure controls improvement. The are frequently updated to
continual alignment. The frequently updated to ensure continual alignment. The company facilitates ensure continual
company facilitates continual alignment. The company facilitates continuous benchmarking alignment. The company
continuous improvement. company facilitates continuous and best practice usage. facilitates continuous
There are fully continuous improvement. improvement. There are There is extensive cross- improvement and
developed and There is extensive cross- fully developed and training for individuals. experienced personnel
integrated metrics. Fully training for individuals. There integrated metrics, and continuously train others.
automated reporting are fully developed and there is fully automated There are fully developed
exists and there is integrated metrics, and there reporting and consistent and integrated metrics and
consistent follow up and is fully automated reporting follow up and action fully automated reporting
action planning. and consistent follow up and planning. Sophisticated with consistent follow up
Sophisticated models are action planning. Sophisticated models are fully and action planning.
Process Maturity
fully integrated into all models are fully integrated integrated in all key Sophisticated models are
key decisions. Results into all key decisions. decisions. fully integrated into all key
are well-documented. decisions.
Managed There is a formal A formal strategy exists and is A formal strategy exists Company policies and A formal strategy exists
strategy aligned with the aligned with company and is aligned with procedures are updated and is aligned with
company’s overall strategies. A formal training company strategies. regularly. HR objectives company overall legal
corporate strategy. A program exists. Experienced Authority and are defined at the front- compliance strategies. A
formal training program personnel perform with few accountability are clearly line level to immediately formal training program
exists. Accountability and errors. Authority and defined and understood. identify interdependencies exists, and experienced
authority are clearly accountability are clearly There is generally and people issues. personnel are involved in
defined and well defined and understood. automated reporting and all legal compliance
understood. There are There is generally automated concerted follow up, aspects. Authority and
well-developed metrics, reporting and concerted follow typically resulting in accountability are clearly
and general automated up, typically resulting in actions. Sophisticated defined and understood.
reporting is utilized. actions. Sophisticated models models are available for There is generally
Sophisticated models are are available for decision - decision making. automated reporting and
available for decision making. concerted follow up,
making. typically resulting in
actions. Sophisticated
models are available for
decision making.
14
HR RISK MANAGEMENT MODEL: FUTURE-STATE
ASSESSMENT (2/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Defined Recruiting goals are Company job requirements Company timekeeping The company has a The company has
documented, but with are well-defined and and compensation standard strategic assigned and
limited alignment with understood. Training supports responsibilities and planning process with communicated legal
company strategies and job needs. There are requirements are well- clear role definitions and compliance responsibility.
defined policies. Job generally experienced defined and understood. budgets. Process These requirements are
requirements are well- personnel within the Reports are reviewed, performance, costs and well-defined, understood,
defined and understood. organization. Many metrics but follow up is policy compliance and training supports job
Training supports job are developed. Reports are inconsistent. There are monitoring are manual. needs. There are
needs. There are well- reviewed, but follow up is well-developed models generally experienced
developed models inconsistent. There are well- available for decision personnel within the
available for decision developed models available making. organization. Many
making. for decision making. metrics are developed.
Reports are reviewed, but
follow up may be
Process Maturity
Repeatable Basic skill requirements Basic skill requirements are Timekeeping procedures The company has some Basic skill requirements
are defined by the defined by the company. are defined by the standard policies and are defined by the
company. There is some There is some training company. There are no procedures. company. There is some
training available. There available and there are some formal metrics for training in legal
is some formal reporting, competent personnel in the compensation. There is requirements available
but it is inconsistently organization. There are no some formal reporting, and there are some
used. There are some formal metrics. There is some but it is inconsistently informed personnel in the
systems available, but formal reporting, but it is utilized. There are organization; however,
they tend to be user- inconsistently utilized. There simple models used there are no formal
developed. are simple models used inconsistently for metrics or processes to
inconsistently for decision decision making. monitor compliance. There
making. is some formal reporting,
but it is inconsistently
utilized.
15
HR RISK MANAGEMENT MODEL: FUTURE-STATE
ASSESSMENT (3/3)
Organization, Performance
Realization Timekeeping &
Recruiting & Hiring Management & Policies & Procedures Legal Requirements
of Value Compensation
Development
Proposition
Initial/Ad hoc The company has no The company has no formal The company has no The company has no The company has no
formal recruiting strategies or objectives. formal strategies or formally documented formal strategies or
strategies or objectives. Development is typically objectives. There is no procedures. The HR objectives. Adherence to
Recruiting is typically performed by inexperienced formal reporting, or strategy is a part-time legal requirements is
performed by and/or untrained people. reporting occurs as activity with no clear dependent on the local
inexperienced and/or There is no formal reporting, requested. There are no definition. individual’s knowledge.
untrained personnel. or reporting occurs as models to support Reporting occurs when
There are no models requested. There are no decision making, and no incidents occur and is
used to support decision models to support decision formal systems are limited.
making. Authority and making, and no formal utilized.
accountability are not systems are utilized.
defined. No formal
systems or databases
are used.
Process Maturity
16
STRATEGIC PLANS SUMMARY (1/4)
The following information was obtained through a series of HR executive management interviews and support investigation.
Management’s future maturity capability rating evaluation for each risk management element can be traced to the following
details.
Timing of
Strategy Accountable Personnel
Implementation
Recruiting & Hiring
1. HR will roll out a standard global new-hire orientation program. The purpose of this program 1. 1. (Date)
is to standardize new-hire orientation globally. The standard will include the company
introduction, department orientation (procurement, call center, etc.), policies and procedures,
standards of conduct for compliance and integrity, and attention to any issues specific to the
region. This may be presented via CD-ROM utilizing a standard PowerPoint presentation.
(Limitation 1)
2. The new-hire checklist is being updated to have one for the employee to complete and one 2. 1. (Date)
for HR to complete for more accountability. The employee checklist will also be more
complete, consisting of the new-hire form completion, policies and procedures receipts, and
standards of conduct for compliance and integrity receipts. The HR checklist will include
background checks and employee’s tasks verifications. Background checks will be done for
all new hires for increased security of assets, but may differ in scope depending on the
position and region. (Limitation 2)
3. The new-hire form will be updated to include a signature for the audit and approval of the 3. 1. (Date)
accuracy of the data entered into the payroll system. (Limitation 3)
4. Templates used for job descriptions are being updated to reflect position descriptions instead 4. 1. (Date)
of job descriptions. The position descriptions will be more specific and fall under job
classifications. Also, the templates are being updated so they can be used globally.
(Limitation 4)
5. HR has created a global agent selection model to standardize competency profiling, sourcing 5. 1. (Date)
best practices, screening and assessment tools, effective interviewing and selection
standards, and management training initiatives to hire the best qualified agents around the
globe. Measurement criteria has been established to evaluate standardized process results
and tools for continuous improvement. (Limitations 5 and 7)
17
STRATEGIC PLANS SUMMARY (2/4)
Timing of
Strategy Accountable Personnel
Implementation
Performance Management & Organizational Development
6. In addition to the first series of workbooks released by the management excellence program 6. 1. (Date)
(MEP) for team leads (see Risk Management Activity 13), another series of workbooks is due
for global release by the MEP for account managers. The series is intended to be a standard
all-inclusive learning experience with materials on responsibilities, roles, processes and
classes to take.
7. HR will roll out the management development program globally. This program is for the team 7. 6. (Location) (Date)
lead level and up. Core competencies have been established and they will be assessed.
Individual development plans (IDP) will be created based on the assessment and reviewed
semi-annually. The purpose of this program is to develop talent within the organization and
reduce turnover.
8. The renovated LEAP, based on the task force’s findings, will be rolled out. The purpose of 8. 1. (Date)
this program is to develop agent and team lead talent within the organization and reduce
turnover. (Limitation 9)
9. This year, corporate employees will be required to complete a questionnaire so that HR can 9. 1. (Date)
determine whether the employee had a one-on-one discussion with his or her supervisor
about his or her duties, responsibilities and performance prior to the merit process. The
purpose is to increase communication and awareness of job expectations and performance
and reduce turnover. (Limitation 10)
10. The employee change form will be updated to include a signature for the audit and 10. 10. (Date)
approval of the accuracy of the data entered into the payroll system. (Limitation 12)
11. (System Time Keeping) is an updated version of (System), which may be implemented 11. 11. (Date)
domestically. This system will forward an agent’s timesheet to his or her supervisor. The
supervisor must approve the hours, or the timesheet will not be forwarded to payroll. STK
will also generate exception reports. This system will decrease the risk of reporting
inaccurate time worked and inaccurate payroll balances in the financial statements.
(Limitation 13 and 14)
18
STRATEGIC PLANS SUMMARY (3/4)
Timing of
Strategy Accountable Personnel
Implementation
Policies & Procedures
12. Standards of conduct for compliance and integrity have been developed and distributed 12. 12. (Date)
worldwide. Communication mediums have included emails, posters, face-to-face
management meetings and employee presentations. The standards will also be revisited
annually during the global annual training.
13. HR will roll out global annual training. This training will refresh employees on policies and 13. 13. (Date)
procedures, standards of conduct for compliance and integrity, and any issues specific to a
region. (Limitation 16)
14. HR will roll out the global HR site review to perform internal management audits of the 14. 14. (Date)
various international HR departments periodically. This will include the adherence to
policies and procedures, standard operating procedures (SOP), safety guidelines,
confidentiality and retention requirements, and other employment compliance issues.
Outside the U.S., this review will be very general in nature and focus on high-risk
processes. Each tier one site will be audited in (Year) and all other sites will be audited in
(Year). Mini audits will be performed as required.
15. Standard operating procedures (SOP) are being updated for all corporate HR processes 15. 15. (Date)
that effect SOA performance. They will consist of detailed narratives of the processes. This
initiative will be rolled out to the rest of the countries in (Year).
19
STRATEGIC PLANS SUMMARY (4/4)
Timing of
Strategy Accountable Personnel
Implementation
Legal Requirements
16. There are organizational changes that will be implemented to move global HR compliance 1. 1. Timing TBD
to the new compliance director. The scope of responsibilities for this position will include an Note: Internal audit is
internal global HR management audit function. Candidates are currently under review. monitoring the
implementation of actions
detailed in the (Year)
regulatory risk
management
assessment. Internal
audit will report the
application of these
actions as they apply to
HR legal considerations
during our follow-up
activities.
20